Of Counsel Emily Wein and Senior Counsel Thomas Ferrante were quoted in a Part B News article, “CMS lets MA providers do telehealth risk adjustment; tight documentation advised,” about a change in CMS policy allowing Medicare Advantage providers to do risk adjustment by telehealth during the coronavirus pandemic.

Wein said guidance on telehealth from Medicare administrative contractors (MAC) is helpful, but suggests that MA providers new to telehealth go a step further and walk through their reasoning in notes. “Maybe in the initial stages, providers should take extra efforts to show professional judgment was exercised in using telehealth, not just assert ‘the MAC said I could,’” she said.

Ferrante said providers should not offer a provisional diagnosis for risk adjustment purposes contingent on the patient coming in when the current emergency is lifted. “I don’t know if the subsequent visit would be reimbursable,” he said. “If you think the provider had enough under the current emergency guidance, what would be the justification for bringing the patient in again?”